Topic
Whistleblower Program
178 published works
Rivkin Rounds
DOJ Launches New FCA Initiative
By Jeff Kaiser
The U.S. Department of Justice (DOJ) recently announced a new initiative to enhance its working relationship with data miners who bring cases as whistleblowers under the False Claims Act (FCA).…
The CLS Blue Sky Blog
Davis Polk Discusses FinCEN Whistleblower Program
By Daniel P. Stipano, Kendall Howell, Charles Marshall Wilson, Neil H. MacBride, Paul D. Marquardt
The Financial Crimes Enforcement Network (FinCEN) published a Notice of Proposed Rulemaking (the NPRM)1 on April 1, 2026, that would establish a comprehensive whistleblower incentive and protection program covering violations of anti-money laundering…
Beyond the First 100 Days
FinCEN Proposes Regulations to Implement Whistleblower Program: 4 Key Takeaways
The program provides new financial incentives for whistleblowers to report information about potential violations of money laundering and sanctions laws. By Joseph M. Bargnesi, Les P. Carnegie, Andrew P. Galdes,…
Cleary Enforcement Watch
Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies (Part Two)
By James Brady‑Banzet, Freeman Chan, Abena Mainoo, Bernardo Massella Duci Teri, Delphine Michot, Miao Zhang, Robert K. Williams, Shuang Zhao, Rüdiger Harms
Introduction[1] In this three-part series, we discuss the outlook for whistleblower programs in the United States under the new administration. Second, we review initiatives relating to whistleblower reports in other jurisdictions…
Quirky Questions
Recent Developments in Federal Whistleblower Programs and Rules
The U.S. Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) have announced several changes to their whistleblower programs and rules, reflecting the federal government’s continued focus on…
The D&O Diary
SEC Rejects Record Percentage of Whistleblower Award Claims
One of the signature features of the Dodd-Frank Act was its creation of the SEC whistleblower program, which includes the possibility for whistleblowers to receive generous bounties. The program has…
Inside Business Immigration
DOJ Adds Federal Immigration Violations to Corporate Whistleblower Awards Pilot Program
As of May 12, 2025, whistleblowers may receive a financial award in exchange for emailing the Criminal Division of the Department of Justice (DOJ) to provide information about potential corporate…
The CLS Blue Sky Blog
Cleary Gottlieb Puts Whistleblowing in Focus
By Victor Hou, Jennifer Kennedy Park, Joon Kim, Abena Mainoo, Matthew Yelovich
In relevant developments in U.S. whistleblower programs over the past year, (1) the Department of Justice (“DOJ”) introduced a three-year pilot program that offers monetary awards for reports relating to…
Whistleblower Law Collaborative Blog and News
2024 Whistleblower News – A Wide Array of Action
2024 was a big year for news in the whistleblower world! In addition to a steady stream of resolutions under the False Claims Act, the Department of Justice launched a…
Cleary Enforcement Watch
Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies. Part One: Developments in the U.S.
By Victor L. Hou, Jennifer Kennedy Park, Joon H. Kim, Abena Mainoo, Matthew Yelovich, Omar Almansoori, Long Dang, Olisa Maduegbuna, Pedro Martini, Joao Salviano
Introduction Whistleblower programs have proliferated and been growing in importance in the criminal and regulatory enforcement landscape globally. In this three-part series, we first discuss recent developments in whistleblower programs…